A Complete Guide to Amazon TIC Audit for Children's Toys

This article systematically explains what Amazon TIC audit is, the required test items and approximate price ranges for different children's toys, the mandatory tests for the US, Canada, UK, and Europe, the similarities and differences across various sites, the specific compliance requirements for packaging and labeling, and the scenarios where a CPSC Registration Card is mandatory. It is applicable to new sellers, rectification of existing listings, TIC random inspection appeals, and other scenarios.

What is Amazon TIC Audit?

TIC is the abbreviation of Testing, Inspection, and Certification.

Audit Logic: Amazon no longer accepts sellers to upload test reports independently. Instead, sellers are required to initiate an application through Seller Central, and the test results or document verification results will be directly synced to the platform system by Amazon-accredited third-party laboratories (such as SGS, Intertek, TÜV, etc.).

Two Core Pathways:

①　Document Verification: If the seller already has a valid compliance report issued within 12 months, they can apply for the TIC service provider to verify the authenticity and completeness of the existing documents.

②　New Product Testing: If there is no valid report or the report version is outdated (e.g., using astm f963-17 instead of the latest F963-23), the seller must send samples for a full set of new tests.

Which Children's Toys Require TIC Audit?

Amazon defines a "children's toy" as a product designed or intended for play by children under 14 years old (under 12 years old in some regions such as the US).

Mandatory Scope: All ASINs that receive compliance notifications in the Account Health Dashboard (AHD).

Special Cases:

①　Non-toy categories with play value: Products such as keychains with plush dolls, children's books (containing stickers or small parts), and children's jewelry with decorative figurines may be classified as toys by the system.

②　Bundles: Each individual item with toy attributes in a bundled product must undergo testing, or the laboratory must evaluate the overall interactive safety of the bundle.

③　Handmade/small-batch toys: Amazon's policy does not exempt handmade products or micro-sellers. Any product labeled as a children's toy must meet the same annual testing requirements.

Basic Inclusion Criteria for TIC Audit:

A product will generally be included in the TIC audit scope if it meets any of the following conditions:

①　The product description, images, or title contains keywords such as toy / kids / baby / toddler / child / boys / girls

②　The product may pose risks of swallowing, choking, chemical hazards, mechanical hazards, or electrical hazards

Common Toy Types:

①　Plastic toys, building blocks, assembly toys

②　Plush toys

③　Educational toys, early childhood development toys

④　Wooden toys

⑤　Electric/electronic toys

⑥　Bath toys, teething toys, soothing toys

Required Tests for Different Children's Toys (By Toy Type)

1. Basic Mandatory Test Items for All Children's Toys

2. Test Content Classification by Toy's Physical Form, Material, and Function

3. Additional Mandatory Tests for Toys Involving Liquids/Pastes/Inks (Key Supplement)

For products such as slime, finger paints, art materials, and bubble solutions, in addition to routine physical/mechanical and flammability tests, they must meet the following strict "purity" and "non-toxicity" requirements:

United States (ASTM F963-23 Section 4.3.6):

①　Microbial cleanliness: Mandatory laboratory testing is required to prove that the material does not contain pathogenic bacteria. This usually involves USP 61/62 pharmacopoeia-level microbial limit tests to ensure qualified total bacterial count and absence of E. coli, Staphylococcus aureus, etc.

②　LHAMA (ASTM d4236): Art materials (e.g., paints, inks) must undergo chronic toxicity assessment by a certified toxicologist, and the label must state "Conforms to astm d-4236".

European Union (EN 71-7 & EN 71-12):

①　Finger paint-specific standard: EN 71-7 mandates that paints must contain bittering agents (to prevent ingestion) and strictly limits the usage levels of 55 preservatives.

②　Nitrosamine restriction: According to EN 71-12, nitrosamines and nitrosatable substances must be tested for elastomers or finger paints with extremely low limits.

③　Canada (sor/2011-17 Section 22):

④　Microbial standard: Requires that the heterotrophic plate count (HPC) of liquid components must be < 10 cfu/ml, and coliform bacteria are not allowed.

⑤　Toxic substance restriction: Strictly prohibits heavy metal salts such as lead, antimony, and arsenic that may come into contact during normal use or in case of breakage/leakage.

Japan (JFSL & ST Part 3):

①　Designated toy supervision: Clay, bubble solution, origami, etc., are classified as "designated toys" and must comply with the requirements of Japan's Food Sanitation Act (JFSL).

②　Special requirements for bubble solution: Surfactant content must be ≤ 3%, and the use of any fluorescent whitening agents is strictly prohibited.

③　Australia (AS/NZS 8124.7):

④　Heavy metal migration: Australia imposes stricter heavy metal limits on finger paints than general toys. For example, the lead limit for general toys is 90mg/kg, while for finger paints, it is only 25mg/kg.

Quick Reference Table for Compliance Requirements in Major Global Markets

Different countries have specific mandatory requirements for laboratory qualifications and testing standards:

Complete Compliance Requirements for Children's Toy Packaging and Labeling (Basic Information + Warning Statements + Icons + Batch Number)

5.1 Basic Information Required on Packaging

Amazon will strictly verify the consistency between "test report data" and "packaging actual photos" during the audit:

(1) Tracking Label: The manufacturer's name, production location, date, and batch number must be permanently marked on both the product and its packaging (mandatory requirement under US CPSIA).

①　Lot / Batch No.

②　Production Date (YYYY/MM or YYYYMM)

(2) Warning Statements:

①　Format: Signal word "WARNING" + equilateral triangle/exclamation mark icon.

②　Font size: Under Japan's ST standard, the height of the signal words "Warning" and "Caution" must be at least 3.5mm, and the content text height must not be less than 2.5mm. In contrast, the US ASTM standard requires the signal word font size to range from 1.19mm to 12.7mm depending on the area of the Principal Display Panel (PDP) of the packaging.

③　Content: Must specify the cause of the risk (e.g., "Contains small parts").

④　When uploading listings for the US site, be sure to fill in the correct enumerated values (e.g., choking_hazard_small_parts) in the <cpsia_cautionary_statement> field to ensure that the yellow warning box is automatically displayed on the detail page.

(3) Age Grading: The detail page, packaging, and test report must be consistent.

①　Note: If the report is tested for ages 3+, the listing must not state 0-3; the minimum recommended age filled in the listing must be greater than or equal to the test age specified in the report.

②　Fill in the manufacturer_minimum_age attribute.

③　Use months as the unit. Example: Age: Over 36 Months

(4) Compliance Markings: CE, UKCA, ST, or PSC markings must be clearly visible with the correct proportions.

(5) Mandatory Warning Icon Requirements for EU / UK (Core of EN 71):

①　0–3 Prohibited Icon (Mandatory) (Red circle with a diagonal line + black baby face + "0–3")

②　Application condition: Any toy not suitable for children under 36 months old

(6) Local Language: The official language of the country where the product is sold. Canada requires bilingual English and French; EU countries require the language of each respective site.

(7) Country of Origin: Made in China

5.2 Mandatory Warning Statements for Children's Toys

5.2.1 US Market: Warning Statement Requirements Under the CPSIA and ASTM F963-23 Framework

Amazon US site requires all toys with choking hazards to display a "yellow warning box" in a prominent position on the product detail page.

Choking Hazard and Small Parts Warnings (16 CFR § 1500.19)

For toys intended for children aged 3 to 6 years old that contain small parts, small balls, marbles, or balloons, specific warning statements must be included. A small part is defined according to 16 CFR Part 1501 as any object that can fit entirely into the standard small parts test cylinder (1.25 inches in diameter, 1 to 2.25 inches in depth).

The format of these warning statements must comply with Section 5 of ASTM F963. The signal word "WARNING" must be in all uppercase letters, and it must be preceded by an equilateral triangle containing an exclamation mark. The font size must be proportional to other text on the Principal Display Panel (PDP) of the packaging, usually requiring the signal word height to be no less than 0.125 inches (approximately 3.2mm).

Specific Warning Obligations in the Updated ASTM F963-23

The ASTM F963-23 version, which has been enforced since April 20, 2024, further strengthens the supervision of battery-powered toys and expandable materials.

①　Battery-powered toys (Section 4.25): For toys containing button or coin batteries, in addition to marking the battery type on the packaging, the instruction manual must include detailed warnings about the swallowing risk. For toys whose battery compartments require special tools to open, the instruction manual must guide parents to keep the tools properly and clearly state that they are not toys.

②　Expandable materials (Section 4.3.2): If a toy contains materials that can expand in water, the packaging must warn of the potential risk of intestinal obstruction.

③　Magnetic toys (Section 4.38): Toys containing high-strength small magnets must warn that swallowing multiple magnets can cause severe intestinal damage or even death.

5.2.2 EU and UK Markets: 10 Core Warnings Under the Toy Safety Directive (TSD)

The market supervision logic of the European Union (EU) and the United Kingdom (UK) is highly similar, both emphasizing the combination of risk assessment and substantive safety requirements. The EU specifies 10 specific categories of warning statements in Annex V of the TSD Directive (2009/48/EC). These warnings must be clearly visible to consumers before purchase, meaning they must appear on both the physical packaging and the Amazon detail page.

Detailed Explanation of Specific Warning Statements in Annex V

These warnings must start with "Warning" or "Warnings" and be translated into the official language of the country where the product is sold.

Language Compliance Requirements for Amazon EU Sites

Amazon strictly enforces the localization language policy for EU sites. Sellers selling on the German site must provide German warnings, those selling on the French site must provide French warnings, and so on. In the Amazon Seller Central backend, sellers must fill in the eu_toys_safety_directive_language attribute and upload product packaging images containing warning labels in the local language. (This needs to be combined with EPSR requirements)

For the UK market, although the UKCA marking was introduced after Brexit, the current UK policy indefinitely accepts products with CE markings that comply with EU standards, provided that the warning statements for products sold on the UK site are in English.

5.2.3 Japanese Market: ST Standard and 2025 Child PSC Mandatory Order

The Japanese toy market not only attaches importance to physical safety but also implements extremely strict chemical testing for toys used by children during the oral stage through the unique Food Sanitation Act.

ST Standard and "Warning/Caution" Format Specifications

The ST standard formulated by the Japan Toy Association (JTA) is voluntary, but it is almost regarded as an access threshold in the Japanese retail market. The ST standard classifies warnings into two levels: "Keikoku" (Warning) and "Chui" (Caution).

①　Format requirements: The height of the words "Warning" and "Caution" must be at least 3.5mm. The height of the main warning content must be at least 2.5mm.

②　Color code: The top of the warning box usually uses an orange or yellow background bar to make it eye-catching.

③　Language requirements: All warning content must be written in Japanese. The focus of Amazon Japan site's audit on overseas sellers is to confirm whether there are Japanese warning statements on the packaging.

5.3 Summary of Core Warning Statement Categories and Application Scenario Guidelines

To achieve seamless compliance across Amazon global sites, sellers should establish a standardized "hazard identification manual". The following summarizes the most common toy hazards and their corresponding compliance operation guidelines.

1. Physical and Mechanical Performance Warnings

Physical hazards are the primary cause of toy recalls, mainly focusing on choking, entanglement, and puncture.

①　Small Parts: Any toy intended for children under 3 years old is strictly prohibited from containing small parts. For toys designed for children over 3 years old that may be misused, they must be labeled "Not suitable for children under 3 years old" and indicate the choking risk.

②　Cords/Strings: Commonly found in pull toys or crib mobile toys. EU EN 71-1 and US ASTM F963 set strict limits on cord length. Extra-long cords must include a warning about the "risk of strangulation/entanglement".

③　Magnets: Especially strong magnetic balls (Buckyballs). Amazon Japan site explicitly lists them as high-risk products. Warnings must emphasize "Do not inhale or swallow" and alert that the adsorption of multiple magnets in the intestines can cause perforation.

④　Acoustic Toys: For toys used close to the ear (e.g., toy phones) and handheld toys. ASTM F963-23 has updated the sound pressure level limits. If the sound level is close to the limit, the packaging must include a warning that says "Do not use near the ear".

2. Chemical and Material Hygiene Warnings

Chemical safety has undergone multiple revisions under the EU TSD Directive, restricting CMR substances, allergenic fragrances, and heavy metal migration.

①　Finger Paints: EU regulations require the inclusion of bittering agents to prevent ingestion, and a warning to "Wash hands after use" must be provided.

②　Soluble Heavy Metals: Although the specific content is not marked on the packaging, the test report (for 19 elements including lead, cadmium, and barium) must be qualified. For the Japanese market, toy coatings that comply with the Food Sanitation Act are the core of the audit.

③　Phthalates: For teething toys and toys that come into oral contact. Both Section 108 of CPSIA and EU reach regulations set strict limits.

3. Functional and Special Environment Warnings

①　Battery Compartment Warnings: Must indicate battery polarity, prohibit mixing new and old batteries, and forbid charging non-rechargeable batteries. Warnings for button batteries must highlight the fatal risk of swallowing.

②　Imitation Protective Gear: Such as toy police helmets. Must clearly state "This product does not provide impact protection" to prevent use in real sports activities.

③　Projectile Toys: Such as archery or pinball toys. Must warn "Do not aim at eyes or face" and strictly prohibit dangerous modifications to projectiles.

5.4 Amazon Multilingual Comparison Table: Compliance Translation Standards for Five Core Languages

According to the requirements of Amazon Seller Central, warning statements must be presented in a "clear, legible, and understandable" manner. The following table integrates compliance translation standards for the five major global Amazon markets.

When is a CPSC Registration Card Mandatory?

According to US CPSC regulations (16 CFR Part 1130), Durable Infant or Toddler Products are required to be accompanied by a registration card.

Product List: Including but not limited to full-size/non-full-size cribs, baby walkers, baby carriers, high chairs, play yards, baby swings, strollers, cradles, bed rails, bathtubs, changing tables, folding chairs, baby trampolines, etc.

Card Requirements:

①　Format: Must be in the form of a prepaid postage postcard and physically attached to the product surface to ensure consumers can notice it.

②　Content: Must pre-fill the manufacturer's name, contact information, model number, and production date; consumers only need to fill in their name, address, and other contact details to receive timely notifications in case of a recall.

③　US Agent: A real and contactable US agent must be specified.

④　Prohibited Use: Information collected through the registration card is strictly prohibited from being used for marketing or promotional activities.

The CPSC Registration Card applies to specific high-risk durable children's products.

Do General Toys Need It?

Ordinary children's toys (building blocks, plush toys, educational toys) usually do not require it; however, if a product is classified as a Durable Infant or Toddler Product, it is mandatory.

Reference Price Ranges for Different Test Combinations (Based on ISO/IEC 17025 Laboratories)

The following prices are industry common range references generated by AI. They are affected by factors such as product complexity, sample quantity, combined testing options, and laboratory brand, and do not constitute a fixed quotation. For details, please consult the corresponding testing institution.

1. Ordinary Children's Toys (Non-liquid / Non-cosmetic / Non-electric)

Notes:

①　For the US/Canada, it is highly recommended to combine tests to significantly reduce costs.

②　The more materials and colors the product has, the higher the cost.

2. Children's Art & Craft Toys

3. Children's Make-up Toys / Play Cosmetics

4. Electric / Electronic Children's Toys

5. Summary Table of Core Variables Affecting Test Prices

Complete Process and Precautions for TIC Audit in Amazon Seller Central

Audit Process Steps

1. Receive Notification: Check the list of affected ASINs in "Account Health" -> "Policy Compliance" -> "Food and Product Safety Issues".

2. Initiate Application: Click "Submit" and select "Verify Your Product" to generate a TRF ID (Test Request Form ID).

3. Select TIC Laboratory: Choose a laboratory from Amazon's accredited list and obtain a quotation.

4. Provide TRF ID and Materials: Provide the generated TRF ID to the laboratory and mail samples or upload existing documents.

5. Audit and Synchronization: After the laboratory completes testing or verification, the results will be directly uploaded to the Amazon system.

6. Result Feedback: Once Amazon approves the audit, the compliance status of the ASIN will be updated to "Approved".

Key Precautions

①　Lead Time: Laboratory testing usually takes 7-15 working days, and the audit period may be longer. It is recommended to initiate the process at least 30 days before the compliance deadline.

②　Report Validity: Existing reports must be issued within 12 months.

③　No Direct Upload: Manual upload of reports by sellers has gradually become invalid; reports not processed through the TIC system will be automatically rejected.

④　Appeal Channel: If a product is misclassified (e.g., adult collectibles judged as children's toys), you can submit evidence (such as product manuals, detail page screenshots) through the appeal function in AHD to apply for the removal of restrictions.